Running an aesthetics, wellness or hormone clinic in Florida: the five rules that bite

1. What does Florida regulate differently for a med spa or wellness clinic?

Five things: whether your entity needs a state clinic licence, whether a nurse practitioner may run it alone, who may inject and who supervises them, a 25-mile rule for supervising injectors off-site, and — the moment anyone prescribes — a PDMP check on every controlled-substance script.

Corporate practice of medicine is not on the list. Florida has no general statute barring a non-physician from owning an entity that employs clinicians, so the management-company structure that Texas, California and New York force is optional here. Florida regulates the clinic instead, which is why the licence question does the work that ownership does elsewhere. Fee-splitting rules in § 458.331 still shape how any management fee is written.

Each of the five gets a section below. Ownership and supervision have their own deep dive in who can own a med spa in Florida; prescribing has one in prescribing TRT and GLP-1s at a Florida med spa. The national version of this question is how to start a med spa.

2. Does my clinic need a Florida Health Care Clinic licence?

If licensed practitioners wholly own it and supervise it, usually not. If anyone else owns any of it, usually yes.

The Health Care Clinic Act defines a clinic as an entity where health care services are provided and which tenders charges for them (§ 400.9905). Charging the patient directly is tendering charges; being cash-pay does not by itself take a clinic outside the Act. What does are the exemptions in subsection (4): an entity wholly owned by one or more physicians who supervise it, alone or with a spouse, parent, child or sibling (paragraph (f)); and an entity wholly owned by licensed health care practitioners who supervise it, are wholly responsible for it and provide services within their own licence (paragraph (g)).

A licensed clinic must appoint a medical director or clinic director who agrees in writing to accept legal responsibility for it (§ 400.9935). The statute then lists what that person owns: verifying that every practitioner holds a current, unencumbered Florida licence, being the owner of the clinic’s records, reviewing billing for fraud, reviewing referral contracts, posting the clinic’s signs and its schedule of charges.

The structure that needs the licence is the common one: a company owned by a non-clinician that employs a nurse practitioner and contracts a physician. The nurse-practitioner-owned practice under paragraph (g) generally does not — provided the NP supervises it and stays inside their own scope, which is exactly the next rule.

3. Can a nurse practitioner run a Florida aesthetics or hormone clinic on their own?

Not autonomously. Florida’s autonomous-APRN registration is limited by statute to primary care.

Section § 464.0123 lets a registered APRN engage in autonomous practice only in primary care practice — family medicine, general pediatrics and general internal medicine, as the board defines them. Certified nurse midwives get a further carve-out. Aesthetics, hormone optimisation and weight management are not primary care, so an APRN doing them works under an established protocol with a supervising physician (§ 464.012), maintained at the practice site, and the physician files notice of the relationship with the Board of Medicine within 30 days (§ 458.348).

Under that protocol the APRN may prescribe, including controlled substances once the required coursework is on file. One limit worth knowing: a Schedule II prescription from an APRN is capped at a seven-day supply (§ 464.012(6)(a)). Testosterone is Schedule III and phentermine is Schedule IV, so the cap does not touch the drugs a hormone or weight programme actually uses.

The trap is the national map. Florida appears on it as a full-practice state, and it is — for family medicine. An article that copies the map into a med spa is wrong, and it is wrong in the state where more aesthetics clinics are opening than anywhere else.

4. Who may inject in Florida, and who has to supervise?

Physicians, and PAs and APRNs under protocol, on their own authority. Registered nurses under a clinician’s order. Nobody holding only a cosmetology or facial-specialist licence.

Chapter 477 licences cover hair, skin and nail services; injecting a neurotoxin or a filler is the practice of medicine or nursing, not cosmetology. A physician who delegates a task to someone not qualified by training, experience or licensure to perform it is subject to discipline under § 458.331(1)(w) — and that is the provision a board complaint about an esthetician with a syringe is written under.

Laser hair removal has its own rule. A licensed electrologist may perform it only under the direct supervision of a physician trained in hair removal, and the Board of Medicine defines direct supervision as the physician being on the premises or supervising by telehealth from within 150 miles with continuous synchronous communication (Rule 64B8-56.002). No physician may supervise more than four electrologists at any one time, in person or by telehealth, and the two must keep jointly written, signed protocols on the premises.

Florida has no med-spa-specific good-faith-exam statute. The evaluation before treatment is governed by the ordinary standard of care, and a telehealth evaluation is permitted where it is sufficient to diagnose and treat the patient (§ 456.47(2)(b)). What the board will ask for is the record that it happened, by whom, before the first treatment.

5. What is the 25-mile rule?

If an NP or PA injects at an office that is not the supervising physician’s primary practice location, and the physician is not on site, Florida treats an aesthetics office as dermatology — and the supervising physician has to be a dermatologist or plastic surgeon.

Section § 458.348(3)(c) applies where the services at the office are primarily dermatologic or skin care services, which the statute says include aesthetic skin care services other than plastic surgery. In that case the physician must be board-certified or board-eligible in dermatology or plastic surgery, may supervise only one such office beyond their primary place of practice, that office must be within 25 miles of it or in a contiguous county, no two of the offices may be more than 75 miles apart, and every address goes to the board. The physician’s primary practice location is the address on their published profile under § 456.041.

Read plainly: a family-medicine physician cannot be the off-site supervisor of an NP-run aesthetics office at all. The two ways out are structural — the physician is on site while the NP treats, or the med spa is the physician’s profile address. Both are decisions about the entity, which is why they belong in the ownership guide.

For primary-care and specialty physicians supervising ordinary satellite offices the limits are four and two additional offices respectively (§ 458.348(3)(a)–(b)) — and both paragraphs expressly exclude offices that are primarily dermatologic or skin care.

6. What changes when the clinic adds hormones or weight loss?

Three state rules land on top of the federal ones. A prescriber, dispenser or their designee must consult the prescription drug monitoring programme before prescribing a controlled substance for a patient aged 16 or over (§ 893.055(8)); if the check is not done, no more than a three-day supply may be prescribed and the reason must be documented. Telehealth may not be used to prescribe a Schedule II drug except for a psychiatric disorder, a hospital inpatient, a hospice patient or a nursing-home resident (§ 456.47(2)(c)) — testosterone is Schedule III and is not caught by the Florida bar, though federal rules still govern the in-person question. And every DEA registrant takes a two-hour course on prescribing controlled substances at each licence renewal (§ 456.0301).

GLP-1s are not controlled substances, so the PDMP rule does not touch semaglutide or tirzepatide. It touches testosterone, and it touches phentermine, which many weight programmes still use. The prescribing guide covers the workflow: prescribing TRT and GLP-1s at a Florida med spa. The national picture of what changes when a med spa starts prescribing is in adding weight loss or hormones to a med spa.

7. What has to be in the chart in Florida?

Four things the state can ask for by name: the protocol, the PDMP check, the evaluation before treatment, and who supervised.

The APRN protocol has to be on site (§ 464.012). The PDMP consultation has to have happened before the script — and because a designee may run it, the record should show who consulted and when (§ 893.055(8)). The evaluation sufficient to diagnose and treat, in person or by telehealth, has to be in the record (§ 456.47(2)(b)). For an NP or PA treating away from the physician’s primary location, the supervising physician and the arrangement have to be identifiable (§ 458.348(3)).

Add the two things every board complaint asks for regardless of state: a consent tied to the treatment on that date, and product, units and lot number per injection site. Free text in a note will not find your patients when a lot is recalled — how to track in-clinic injections electronically is about exactly that.

Whatever software you run, these should be fields, not prose. A board request is a search, not a read.

8. Frequently asked questions

Is Florida a corporate-practice-of-medicine state?
Not in the strict sense. There is no general Florida statute barring a non-physician from owning an entity that employs clinicians. Florida regulates the clinic through the Health Care Clinic Act instead, and fee-splitting rules in § 458.331 still apply to management arrangements.

Can an esthetician inject Botox or filler in Florida?
No. Chapter 477 licences cover hair, skin and nail services. Injecting is the practice of medicine or nursing, and a physician who delegates it to someone not licensed for it is subject to discipline under § 458.331(1)(w).

Can a nurse practitioner own a med spa in Florida?
Yes. A practice wholly owned and supervised by licensed practitioners is generally exempt from the clinic licence under § 400.9905(4)(g). The NP still cannot practise autonomously outside primary care, so a protocol with a supervising physician is required (§ 464.0123, § 464.012).

Does a Florida med spa need a medical director?
A licensed clinic must appoint a medical or clinic director who accepts legal responsibility in writing (§ 400.9935). A clinic exempt from the licence has no statutory director, but every APRN and PA in it needs a supervising physician regardless, and the 25-mile rule can apply to that physician.

Can I prescribe testosterone by telehealth in Florida?
Florida bars telehealth prescribing of Schedule II only (§ 456.47(2)(c)); testosterone is Schedule III. Federal DEA rules govern whether a prior in-person evaluation is required — see EPCS and telehealth testosterone in 2026 — and the PDMP must be consulted before each script.

Does the PDMP rule apply to GLP-1 prescriptions?
No. Semaglutide and tirzepatide are not controlled substances. The rule in § 893.055(8) applies to Schedule II–V drugs, which in a wellness clinic means testosterone and phentermine.